Pension Protection Act Blog

The new Form 5307 is available at IRS.gov, and it is better. Since the old Form 5307 can be used until September, 2008, and filing season for the EGTRRA defined contribution prototypes and volume submitter plans begins May 1, 2008, we had a competition around the office today to see which Form 5307 is faster to complete - new Form 5307 or Old Form 5307. New Form 5307 won easily.

The difference between new Form 5307 and old Form 5307 - the information remains the same, only the boxes have changed. The new Form 5307 contains boxes which are easy to type in, and then tab onto the next box. While some might find the old Form 5307 prettier to look at, the new Form 5307 is simply more efficient.

One interesting change is that the signature line with the penalty of perjury statement has moved, and is now prominently available immediately after the address information but before any of the substantive information has been provided. I read a study a few months ago about redesigning tax forms so that the penalty of perjury statement was at the beginning of the form instead of the end of the form. The theory was that by signing a penalty of perjury statement before providing the information, the preparer would be compelled on a subconscious level to complete the form more accurately. I am not sure if that was the IRS’ reasoning behind moving the signature line, or if it was simply that they wanted to keep the signature line on page one.

The only confusing part of the new Form 5307 may be Line 1a, which states that it is for the number assigned under Section 6.19 of Revenue Procedure 2007-6. This is the number which practitioners would have written in green ink at the top of the old Form 5307 and which they would have been assigned for participating in the pre-registration program for practitioners filing 30 or more Form 5307s at the same time. The exact language from Section 6.19 of Rev. Proc. 2007-6 is:

.19 An authorized representative who will be submitting determination letter applications for 30 or more on-cycle plans at one time should pre-notify the Service of the submissions so that the Service can endeavor to ensure that the applications will be reviewed in one area. The pre-notification should be e-mailed to David.J.Nelson@irs.gov and should include the following information: the firm name, the names of the authorized representative(s) submitting the plans, the name and phone number of the contact person, the approximate number of submissions, and the expected date(s) of the submissions. Upon receipt of the e-mail, the representative will be contacted and assigned a number that must be entered in green ink at the upper left hand corner of the applications. For further discussion, see the Spring/Summer 2002 edition of the Employee Plans Newsletter available at www.irs.gov/retirement.

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